In A.I.G. Uruguay Compania de Seguros, S.A. v. AAA Cooper Transp., 334 F3d 997, 1003-1004 (11th Cir. 2003), the carrier's recitation of good condition and contents on a bill of lading may suffice as the necessary proof of condition. Id.
But where the shipment is in a sealed container and cannot be examined by the carrier, a bill of lading "can attest only to apparent or external good condition, and the shipper may reasonably be required to present some additional evidence of the condition of the goods at the time of delivery." A.I.G. Uruguay, 334 F3d at 1004.
As to the additional evidence required, we recognize the rule established in the Eleventh Circuit stating that the evidence varies depending on whether the shipment at issue was damaged, but still identifiable, as opposed to being lost, destroyed, or damaged to such an extent that it cannot be determined what was contained in the shipment. Id.
When a sealed shipment is damaged in transit, but it can still be determined what was contained therein, then the only question is its original condition when it was delivered to the carrier, and "reliable, substantial circumstantial evidence of condition will suffice to prove a prima facie case." A.I.G. Uruguay, 334 F3d at 1004.